Government Affairs and Advocacy

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This is a channel that we use to keep members in the loop about the latest policy documents and developments. Our work in advocacy cuts across all areas of expertise and impacts all of our members.

Our Director of Government Affairs & Advocacy, Cynthia Smith, and our Advocacy Manager, Jenna Thoretz, post regular updates so our members are alerted to changes in the sector as they happen. We encourage everyone who joins Connect to become part of this community and to keep up to date with the information shared here. Posts to this community go live on our website, and you may wish to use the anonymous posting option if you have a question to ask here.

USAID: UEI/SAM Registration Exception Acquisition and Assistance Policy Directives (22-03, 22-04)

  • 1.  USAID: UEI/SAM Registration Exception Acquisition and Assistance Policy Directives (22-03, 22-04)

    Posted 09-28-2022 11:43

    As was partially posted on Connect yesterday, USAID recently published two new Acquisition and Assistance Policy Directives (AAPDs), which you can find here: AAPDs website. Given the recent difficulties and delays that entities face in obtaining unique entity identifiers (UEIs) and registering in the System for Award Management (SAM), these AAPDs provide guidance on flexibilities for acquisition and assistance, respectively, that may be used in urgent circumstances requiring the award:

    • AAPD 22-03 ("UEI/SAM Registration Exception for Acquisition Awards"): This AAPD details a recently-approved class deviation that provides a new, temporary exception for UEI/SAM registration requirements for acquisition awards. This class deviation allows a CO to issue a contract to an entity that can prove it has initiated the SAM registration process, but is not yet actively registered at the time of offer submission, when there are urgent circumstances requiring the award of the contract to meet the agency's needs.
    • AAPD 22-04 ("UEI/SAM Registration Exception for Assistance Awards: 2 CFR 25.110(c)(2)(iii)"): This AAPD provides supplementary guidance for the use of an existing exception under 2 CFR 25.110(c)(2)(iii) for assistance awards. This exception allows AOs to make an award when there are exigent circumstances that prohibit the applicant from obtaining a UEI and completing SAM registration prior to receiving the award.

    These AAPDs have specific instructions and guidance that COs/AOs must follow when exercising these flexibilities. Both AAPDs are available for awards issued only before January 31, 2023. 

    Cynthia Smith
    Director, Government Affairs and Advocacy